United States District Court, N.D. California
DENNIS
J. HERRERA CITY ATTORNEY CHERYL ADAMS CHIEF TRIAL DEPUTY
PETER J. KEITH DEPUTY CITY ATTORNEY BY PETER J. KEITH
ATTORNEYS FOR DEFENDANT CITY AND COUNTY OF SAN FRANCISCO
CITY AND COUNTY OF SAN FRANCISCO’S
ADMINISTRATIVE MOTION TO CONTINUE CASE MANAGEMENT CONFERENCE;
DECLARATION IN SUPPORT; ORDER [UNOPPOSED] [CIVIL LOCAL RULE
6-3]
HONORABLE HAYWOOD S. GILLIAM JR. UNITED STATES DISTRICT JUDGE
ADMINISTRATIVE
MOTION TO CONTINUE CASE MANAGEMENT CONFERENCE
(UNOPPOSED)
Pursuant
to Civil Local Rule 6-3, Defendant City and County of San
Francisco (“San Francisco”) respectfully moves
the Court to continue the case management conference, set for
Tuesday July 19, 2016, at 2 p.m. (per the Court’s Order
of yesterday, Dkt. No. 29), to a new date of Tuesday August
2, 2016, at 2 p.m.
Mr. Jen
does not oppose the motion and has agreed with the request.
(Exh. A.) The matters to be addressed under Civil Local Rule
6-3 are addressed in the following declaration of counsel. //
DECLARATION
OF PETER J. KEITH REGARDING GOOD CAUSE
I,
Peter J. Keith, declare as follows:
1. I am
a Deputy City Attorney for the San Francisco City
Attorney’s Office, counsel of record in this case for
defendant City and County of San Francisco. Unless otherwise
indicated, I have personal knowledge of the facts set forth
below.
2.
Yesterday, on July 11, 2016, the Court issued its Order on
San Francisco’s motion to dismiss and special motion to
strike, which were heard on January 21, 2016. Dkt. No. 29.
The Court’s Order of July 11, 2016 also set a case
management conference for Tuesday July 19, 2016 at 2 p.m.
Id.
3. Good
cause for continuance of the case management conference
exists, in that I have a pre-existing calendar conflict on
Tuesday July 19. On the following Tuesday July 26 at 2 p.m.,
I have another pre-existing calendar conflict; furthermore,
the Court’s scheduling notes on the Northern District
website indicates that the Court is not setting hearings on
that date. I am available on August 2 at 2 p.m.
4. Mr.
Jen has agreed to the requested continuance. A true and
correct copy of Mr. Jen’s email agreeing to the request
is attached as Exhibit A.
5.
There has been no previous request to continue this case
management conference. The only prior request to modify a
schedule in this case was when San Francisco requested two
additional days to file its reply brief, after Mr.
Jen’s opposition brief was filed late. Dkt. No. 20.
6. The
requested continuance is not expected to affect any other
deadline in the case.
I
declare under penalty of perjury of the laws of the United
States and of California that the foregoing is true and
...